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  • The internet has made international borders inconsequential for e-commerce and business transactions, leaving countries with the challenge of developing a workable tax policy for those online dealings.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $11.2 billion American Realty Capital Properties Cole Real Estate Investments Weil, Gotshal & Manges Sullivan & Cromwell - Andrew Mason / Wachtell, Lipton, Rosen & Katz - Eiko Stange Acquisition $4.85 billion Crown Castle International AT&T Sullivan & Cromwell Acquisition $2.4 billion Oman Oil Oxea Vinson & Elkins Hogan Lovells Acquisition $1.53 billion Softbank Supercell Morrison & Foerster Fenwick & West - David Forst, Jay Cosel / White & Case Acquisition $1.26 billion Softbank Brightstar Morrison & Foerster Cleary Gottlieb Steen & Hamilton / K&L Gates Acquisition $620 million RR Donnelley & Sons Consolidated Graphics Sullivan & Cromwell Haynes & Boone Acquisition $400 million Trafigura / Mubadala Development MMX Porto Sudeste Shearman & Sterling / Stocche Forbes Padis Filizzola Clapis Advogados Davis Polk & Wardwell / Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados Acquisition $314 million APR Energy GE Capital (power generation business) Sullivan & Cromwell Acquisition $301.8 million Wumart Stores C.P. Lotus Davis Polk & Wardwell Freshfields Bruckhaus Deringer Acquisition $255 million Synaptics Validity Sensors Fenwick & West Acquisition $240 million MedImmune Spirogen Covington & Burling Acquisition Undisclosed Tower Three Partners NTS Weil, Gotshal & Manges Olshan Frome Wolosky / Sichenzia Ross Friedman Ference Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Bridge Facility $5.5 billion McKesson Merrill Lynch / Goldman Sachs Morrison & Foerster Davis Polk & Wardwell - Kathleen Ferrell Revolving Credit Facility $1 billion Twitter Morgan Stanley Wilson Sonsini Goodrich & Rosati Davis Polk & Wardwell - Rachel Kleinberg Bonds Offering $700 million Greenland Hong Kong HSBC / JP Morgan / Morgan Stanley / BOCI / Deutsche Bank / Citigroup / Goldman Sachs Davis Polk & Wardwell - Alon Gurfinkel Linklaters / Commerce & Finance Law Offices Bridge Loan Facility $190 million Air India Deutsche Bank Amarchand & Mangaldas Hogan Lovells
  • One business truism rarely discussed, not just among tax professionals but the wider business community, is just how widespread the use of spreadsheets remains in the modern business world. Applications such as common-or-garden Excel are the core medium for corporate data across small businesses right up to global multinationals and financial services giants, used by all of these as vehicles for business critical data, including tax and accounting information.
  • Grant Thornton takes a look at the year ahead for transfer pricing in the UK, and makes predictions on what will happen with legislation and policy developments, including intangible asset guidance.
  • On August 5 2013, the German Ministry of Finance issued for public discussion the draft version of a new Regulation on the Profit Attribution to Permanent Establishments (PE regulation). The PE regulation aims to provide details on the application of the authorised OECD approach (AOA) that was recently implemented in the German tax law.
  • UK Patent Box; Australia open for business; EC Gibraltar state aid; Semeta tax reform; Developing countries cooperation
  • Type of Agreement Country Country Date Signed Tax Information Exchange Agreement UK Uruguay October 14 2013 Double Taxation Avoidance Agreement (Protocol) Brazil India October 15 2013 Double Taxation Avoidance Agreement Curaçao Malta October 17 2013 Tax Information Exchange Agreement Gibraltar Guernsey October 22 2013 Tax Information Exchange Agreement Guernsey Slovakia October 22 2013 Automatic Tax Information Exchange Agreement Guernsey UK October 22 2013 Automatic Tax Information Exchange Agreement Jersey UK October 22 2013 Double Taxation Avoidance Agreement (ratified) Belarus Indonesia October 24 2013 Double Taxation Avoidance Agreement (ratified) Belarus Singapore October 24 2013
  • Taxpayers globally are experiencing significantly higher numbers of audits and it has never been more important for them to pay close attention to any business restructurings. However there are various options when choosing the right supply chain model.
  • On October 24 2013 the Irish Finance Bill was published, including measures to reform the taxation of Irish incorporated entities.
  • The European Commission has launched an investigation into the new corporate tax regime in Gibraltar, after a June 2012 complaint from Spain that the regime contravenes state aid rules.